ML023250497
| ML023250497 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/13/2002 |
| From: | Faggert P Dominion Virginia Power |
| To: | Darton T Office of Nuclear Reactor Regulation, State of VA, Dept of Environmental Quality |
| References | |
| Download: ML023250497 (13) | |
Text
Pamela F. Faggert 011111n111 Vice President and Chief Environmental Officer 5000 Dominion Boulevard, Glen Allen, VA 23060 Phone 804-273-3467 November 13, 2002 Mr. Terry H. Darton Air Permit Manager Virginia Department of Environmental Quality Northern Virginia Regional Office 13901 Crown Court Woodbridge, VA 22193 Re: North Anna Power Station (Registration No. 40726) Air Permit Application for a Portable Concrete Plant
Dear Mr. Darton:
North Anna Power Station (North Anna) is scheduled to undergo repairs over the next several months. Approximately 490 yards of concrete will be required in order to complete these repairs. Dominion is proposing to contract Williams Concrete, Inc. of Maumee, Ohio, to provide a portable batch concrete plant at North Anna to produce the concrete. It is anticipated that the concrete plant will be on-site from early December 2002 through March 2003. The concrete plant will be located on North Anna property, approximately 0.5 miles from the pour site.
Raw materials in support of the project will include one 500 ton pile of sand, one 500 ton pile of aggregate, and 125 tons of cement in watertight bins. The piles of sand and aggregate will be covered and penned-in on all four sides while not being used.
A 241 horsepower diesel generator will power the concrete plant. In addition, two small heaters will be used in the event of extreme cold weather. One heater will be a propane-fired water heater to heat the water used in the concrete. The other heater will be a diesel-fired ground heater, which will heat ethylene glycol that will be circulated through piping. The ground heater piping would be placed on the aggregate pile to keep the aggregate from freezing. Both heaters are less than 1 MMBtu/hr heat input capacity.
Pursuant to discussions with Mr. Dean Gossett of your office, pages 1, 2, and 3 of the Air Permit Application (Form 7) have been included (Attachment 1) and Mr. Mark Williams, President of Williams Concrete, Inc. (owner of the concrete plant), has signed the Form.
Mr. Terry H. Darton November 13, 2002 Page 2 Conservative calculations of the raw material handling and truck traffic using AP 42 emission factors yielded estimates of 1.56 tons of total particulate matter (PM) per year and 0.33 tons of particulate matter less than 10 microns (PM1o) per year.
Actual site conditions will result in much lower PM and PM1o emissions.
Emissions from the diesel generator and heaters in addition to the PM and PM10 emissions from raw material transfers and truck traffic will be far below permit exemption levels in 9 VAC 5-80-1320(C). See Attachment 2 for emissions calculations.
If you have any questions, please contact Andy Gates at 804-273-2950 or AndyGates@dom.com.
Sincerely, Pamela F. Faggert - Form 7 (pages 1-3) - Emissions Calculations cc:
U. S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 Mr. M.J. Morgan NRC Senior Resident Inspector North Anna Power Station
ATTACHMENT1 COMMONWEALTH OF VIRGINIA Department of Environmental Quality AIR PERMIT APPLICATION Generalinformabon CHECK ALL FORMS THAT APPLY AND LIST ALL ATTACHED DOCUMENTS CRITERIA POLLUTANT EMISSIONS, Page 14 MAP AND LOCALITIES LIST (information), Pages iu-i TOXIC OR HAP OR OTHER EMISSIONS. Page 15 CONFIDENTIAL INFORMATION, Page vis OPERATiNG PERIODS, Page 16 FORMULA-BASED HAZARDOUS AIR POLLUTANT INFORMATION.
Page viii LIST ATTACHED DOCUMENTS HAZARDOUS AIR POLLUTANT LIST (information), Pages IX-x
-MAP of SITE LOCATION REQUEST FOR LOCAL GOVERNMENT CERTIFICATION FORM.
Pages xeux-a FACILITY SITE PLAN X CONTENTS AND DOCUMENT CERTIFICATION, Page 1 PROCESS FLOW DIAGRAM/SCHEMATIC X GENERAL INFORMATION, Page 2 MSDS or CPDS SHEETS X GENERAL INFORMATION (continued), Page 3 X ESTIMATED EMISSIONS CALCULATIONS
_ FUEL-BURNING EQUIPMENT, Page 4 - STACK TESTS
_ PROCESSING, Page 5 -AIR MODEL DATA
__ INKS, COATINGS. STAINS. AND ADHESIVES, Page 6 LOCAL GOVERNING BODY CERTIFICATION FORM
__ INCINERATORS. Page 7 VOLATILE ORGANIC COMPOUND/PETROLEUM STORAGE TANKS.
Page 8 VOLATILE ORGANIC COMPOUND/PETROLEUM STORAGE T.ANKS CONTINUED. Page 9
_LOADING RACKS AND OIL-WATER SEPARATORS, Page 10
__ STACK PARAMETERS AND FUEL DATA. Page 11 i_ AIR POLLUTION CONTROL AND MONITORING EQUIPMENT, PAGE 12 AIR POLLUTION CONTROL/SUPPLEMENTAL INFORMATION, PAGE 13 Note added form sheets above; also indicate the number of copies of each form in blank provided.
DOCUMENT CERTIFICATION FORM (see other side for instructions)
I certify under penalty of law that this document and all attachments[as noted above] were preparedunder my direction orsupervision in accordancewith a system designedto assurethatqualifiedpersonnelproperlygather and evaluate the informationsubmitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsibleforgatheringand evaluatingthe information, the informationsubmitted is, to the best of my knowledge and belief, true, accurate,and complete. I am aware that there are significantpenalties for submitting false information, incjuding the possibility of fine and imprisonmentfor knowing violations.
SIGNATURE. DATE:: _ _ _ _ _ _7-.
NAME Mark illiams TITLE President REGISTRATION COMPANY Williams Concrete, Inc NUMBER: N/A References Virginia Regulations, 9 VAC 5-80-1 0.D.4. See reverse of this form for Instructions -
ý.__ I Page Revised April 15, 2002 I FORM 7
COMMONWEALTH OF VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR PERMIT APPLICATION GENERAL INFORMATION PERSON COMPLETING FORM DATE I REGISTRATION NUMBER Bob Asplund 11-9-02 I N/A REASON(S) FOR SUBMISSION:
El OPERATING PERMIT E RENEWAL OF OPERATING PERMIT (CURRENT PERMIT EXPIRATION DATE:
MODIFICATION THIS PERMIT IS APPLIED FOR PURSUANT TO THE FOLLOWING PROVISION(S) OF THE VIRGINIA REGULATIONS OR FEDERAL REGULATIONS (IF KNOWN):
9 VAC 5-80-1100 (NEW AND MOD. SOURCES)
SNEW SOURCE (PSD, MAJOR 9 VAC 5 Chapter 80, Article 8 SOURCES)
- 9 VAC 5 Chapter 80, Article 9 (NON-ATTAINMENT MAJOR SOURCES)
LiEXEMPT E P ION P-ERMITS)
_ 9 VAC 5 Chapter 80, Article 5 (STATE UWOP AMENG El REGISTRATION UPDATE El OWNERSHIP OR NAME CHANGE - EFFECTIVE DATE:
(COMPLETE PAGES 1 AND 2 ONLY)
E OTHER (SPECIFY) discuss the potential benefits of implementing P2 practices at your facility?
Would you be interested in a DEQ Pollution Prevention (P2) site visit to visit is not limited to air pollution Issues. Site visits can yield air/water Please note that there Is no charge for this service and that the site facility. The purpose of these visits is not to assess compliance with pollution or waste minimization recommendations that can benefit your applicable regulatory requirements.
= Yes [TZ No If yes, would you prefer the P2 site visit to occur:
[ 1 Before permit issuance After permit issuance P 0. Box 147 Maumee, OH 43537-0147 NUMBER OF EMPOLYEES AT SITE: PROPERTY AREA AT SITE' TELEPHONE NUMBER: 0.75 Acres (888) 893-3251 4 AND FULL STREET ADDRESS OR DIRECTIONS:
EXACT SOURCE LOCATION - INLCUDE NAME OF CITY (COUNTY) end of Route 700, Louisa County, Virginia North Anna Power Station - North FORM 7 Page Revised April 16, 2002 I
COMMONWEALTH OF VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR PERMIT APPLICATION GENERAL INFORMATION (continued)
COMPANY NAME DATE REGISTRATIUN NUMBErK 11-9-02 N/A Williams Concrete, Inc.
YES X NO IS THE FACILITY TO BE PERMITTED AS A PORTABLE PLANT?
AT THIS FACILITY:
DESCRIBE THE PRODUCTS MANUFACTURED AND/OR SERVICES PERFORMED This portable concrete plant will be on-site at North Anna Power Station from December 2002 through March 2003 and will produce approximately 390 yards of concrete to complete facility repairs.
FACILITY:
LIST THE STANDARD INDUSTRIAL CLASSIFICATION (SIC) CODE(S) FOR THE 13531 PRIMARY SIC SECONDARY SICs OR CONTROL BY THE PLEASE LIST ALL THE FACILITIES IN VIRGINIA UNDER COMMON OWNERSHIP OWNER OF THIS FACILITY:
N/A emissions unit or MILESTONES. This section is to be completed if the permit application includes a new modification to existing operations.
I ESTIMATED COMPLETION DATE MII FSTONES* - I Z5 1AM I I1kz /LI MILESTONES* - I 3-31-03 New equipment installation 12-1-02 i I Modification of existing process or equipment -i Start-up dates December 2002 I
For new or modified installations to be constructed in phased schedule, give construction/installation starting and completion date for each phase.
FORM 7 Page Revised July 31, 2001 ;3
ATTACHMENT 2 PM - Raw Materials &Truck Traf North Anna Power Station Concrete Batch Plant PM Emissions from Raw Materialsand Truck Traffic Project entails making 490 yards of concrete for facility repairs.
Each yard weighs approximately 3,500 lbs.
Table displaying the corno nent weights of 386 yards of concrete
- c~ n~D~' Cemeo~Su lment San w.rv14WW1r* w lbhf k 209,281 31,115 608,664 794,929 71,011 1,715,000 0io ercentbf~total.Weight 12.2% 1 1.8% 35.5% 46.4% 4.1 n %
100.0 DIORImtl@el@n frnm Pnrtablh Conncrete Plant rtmlgslon Factors from Table 11.12-2 In AP-42 dated 101011 d c vi ~M~ s ohjrE~
or X -A
~ FmlsPr6m er nSdtra fterto1WeVatedblrn'U 0.0021 lbs PM/ton 304 tons sand 1
~gregate $ ertt~o'dvat0
________________ 0.0069 lbs PM/ton 397 tons aggregate 3 tatb. 0.72 lbs PM/ton 105 tons cement dust 75 p 3.14 lbs PM/ton 16 tons cement supp 49 WaelghLNpp-entlo~dil1rn tr 0.0051 lbs PM/ton 82 tons dry materials 4 Ml~t6lb 0.22 lbs PM/ton 822 tons dry materials 181 TOTAL PM EMISSIONS FROM PORTABLE CONCRETE PLANT 313 Uncontrolled emission factors. The cement transfer point will be controlled by a 98.5% efficient baghouse.
PM - Raw Materials &Truck Traf Vehicle Traffic PM Emissions (paved roads) [from Section 13.2.1 of AP-42]
E = k (sL/2)065 (W/3) 15 where:
E = particulate emission factor (lbs PMNMT) k particle size multiplier for particle size range and units of Interest 2
sL = road surface silt loading (g/m )
W = average weight (tons) of the vehicles traveling the road E= 0.082 lbs PM/VMT x (400 grams/rM2 /2)065 x (20.5 tons /3)1s = 46 lbs PMNMT Worst case according to AP-42. 14 tons of concrete per truck, 13.5 ton trucks PM emission factor from Table 13 2-1.1.
1 trip empty, 1 trip full The length of road to travel from the portable concrete plant to the reactor Is approdmately 0.5 miles for a roundtrdp distance of 1.0 miles.
The number of truck roundtrips will be: 490 yards of concrete = 61 8 yards concrete/truck Total distance traveled for the concrete trucks will be: 61 roundtdps x 1.0 miles/lfp = 48 VMT Emissions from truck traffic = 46 lbs PM/VMT x 61 VMT 2,809 lbs PM TOTAL PM Emissions from Portable Concrete Plant and Associated Truck Traffic = 1.56 tons
PM10- Raw Matris &Truck Traf North.Anna Power Station Concrete Batch Plant PM 10 Emissions from Raw Materialsand Truck Traffic Project entails making 490 yards of concrete for facility repairs.
Each yard weighs approxdmately 3,500 lbs.
Table displaying the component weights of 386 yards of concrete
.arame e C"Re. st I m tr .t I we 1 b 209,281 31,115 608,664 794,929 71,011 1,71,00
ý-.O rgoebntVt~t ht etalW 12.2% 1.8% 35.5 46.4%/ 4.1% 10.0 PM. Emissions from Portable Concrete Plant [Emission Factors from Table 11.12-2 In AP-42 dated 10/011 SandiansferloevatedlIdb! 0.00099 lbs PM1O/lon 304 tons sand 0 t' wrogat 'rfSf0~Pt 0.0033 lbs PM10/ton 397 tons aggregate I
)In stra e1sf16 m c 0.46 lbs PM1 0/ton 105 tons cement dust 48 mabo .
eiia 1.10 lbs PMlO0/on 16 tons cemnent supp 17 W l0Mdadrn
- blqMl , 0.0024 lbs PM10/ton 822 tons dry materials 2 Mixed lowir( l
'mbolftr 0.08 lbs PM10/ton 822 tons dry materials 64 TOTAL PMlo EMISSIONS FROM PORTABLE CONCRETE PLANT 133
- Uncontrolled emission factors. The cement transfer point will be controlled by a 98.5% efficient baghouse.
PM10- Raw MatrIs &TruckTraf Vehicle Traffic PM1o Emissions (paved roads) [from Section 13.2.1 of AP-42]
E = k (sL/2)0 6s (W/3)'-5 where:
E = particulate emission factor (lbs PMoIVMT) k = particle size multiplier for particle size range and units of Interest 2
sL = road surface slit loading (g/m )
W = average weight (tons) of the vehicles traveling the road E= 0.016 Ibs PM10/NMT x (400 grams/rn /2)065 x (20.5 tons / 3)1,5 - 9 lbs PM10NMT PM10 emission factor from Table 13.2-1.1. Worst case according to AP-42. 14 tons of concrete per truck, 13.5 ton trucks 1 trip empty. 1 trip full )
The length of road to travel from the portable concrete plant to the reactor Is appromxmately 0.5 miles for a roundtrip distance of 1.0 miles.
The number of truck roundtrps will be: 490 yards of concrete - = 61 8 yards concrete/truck Total distance traveled for the concrete trucks will be: 61 roundtrips x 1.0 miles/trip = 61 VMT PM10 Emissions from truck traffic = 9 lbs PM10NMT x 61 VMT 528 lbs PM10 TOTAL PM10 Emissions from Portable Concrete Plant and Associated Truck Traffic = 0.33 tons
Diesel Generator & Heater North Anna Power Station Concrete Batch Plant Diesel Generator&
Ground HeaterEmissions The concrete batch plant will be using a 241 Hp Caterpiller 3208 diesel generator to power the mixing drum.
In the event of extreme cold weather, a diesel-fired 'ground heater" will be used to keep the aggregate from freezing. The generator and ground heater are expected to bum no more than 4,000 gallons of diesel fuel to complete the project.
4,000 gallons diesel X 137,000 BTU/gal = 548 MMBtu Total Heat Input Diesel Generator Emissions JEmlsslon Factors from Table 3-3-1 In AP42 dated 10/96]
_K ja W ,ý-,vz N, .. I I ý,;5 , ý`,_ W, 1 44 Of MM - -I,& F&Oigl I
1.21 tons 4
4.41 lb/MMBtu 0.26 tons 00,1MY 0.95 lb/MMBtu 02 IMMI*MU 0.08 tons 0.31 Ib/MMBtu 0.08 tons 0.36 IbflMBtu 0.10 tons
North Anna Power Station Concrete Batch Plant Hot Water HeaterEmissions In the event of extreme cold weather, a hot water heater will be used to heat water for use In the concrete.
The heater is rated at 900,000 Btu/hr. As a very conservative estimate, the calculation has assumed operation of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s/day for 1 full month.
0.9 MMBtu/hr x 31 days/month x 24 hrs/day 669.6 MMBtulmonth 669.6 MMBtulmonth I 0.094 MMBtufgal = 7,123 gallons propane Emission Factors for LPG Combustion [Emission Factors from Table 1.5-1 In AP-42 dated 10/96]